Dec 18, 2018 Independent Oil, Gas Producers Comment on EPA Methane Rule Proposal
Groups Share Recommend Changes to EPA’s Latest Revision to Better Account for Smaller Operators, Existing State Efforts and Emerging Technology
WASHINGTON, D.C. – The Independent Petroleum Association of America (IPAA), representing the independent producers that develop 90 percent of America’s oil and natural gas wells, jointly submitted comments on Monday with 18 other national and state trade associations (collectively the “Independent Producers”) to the U.S. Environmental Protection Agency regarding the agency’s reconsidered rules on emission standards for new, reconstructed, and modified sources of energy production.
The comments detail how the Independent Producers support the EPA’s proposed revisions to New Source Performance Standards, but believe additional changes are essential in how the regulatory framework addresses low production wells, storage vessels, alternative methods of emissions limitations (AMEL) including emerging technology and recognition of state programs monitoring emissions.
Lee Fuller, IPAA Executive Vice President, said of the revisions, “From the beginning of the EPA’s rulemakings in 2011, the Independent Producers have tried to illustrate to the EPA that their “one-size-fits-all” approach to regulating this industry is inappropriate and disproportionally impacts conventional operations and small businesses.
“We appreciate the EPA’s recent effort to improve and to tailor 40 C.F.R. Part 60, Subpart OOOOa (“Subpart OOOOa”) to reduce the impact on the Independent Producers and their individual members while still providing more than adequate protection of the environment. Our comments highlight the need for low production wells to not be given the same regulatory treatment as high production wells, for cooperative federalism within the Clean Air Act to be implemented and states’ emissions programs to be recognized, and for rules to be written in a way that allows for emerging technologies for capturing methane to be adopted and deemed compliant.”
The Independent Producers have participated individually or through the Independent Producers in most, if not all, of the rulemakings and associated litigation since the Environmental Protection Agency proposed to revise the New Source Performance Standards (“NSPS”) for the Oil and Natural Gas Sector in August 2011.
The follow energy industry associations are among those signing the joint comments:
- Independent Petroleum Association of America (“IPAA”)
- American Exploration & Production Council (“AXPC”)
- Domestic Energy Producers Alliance (“DEPA”)
- Eastern Kansas Oil & Gas Association (“EKOGA”)
- Illinois Oil & Gas Association (“IOGA”)
- Independent Oil and Gas Association of West Virginia, Inc. (“IOGA-WV”)
- Indiana Oil and Gas Association (“INOGA”)
- International Association of Drilling Contractors (“IADC”)
- Kansas Independent Oil & Gas Association (“KIOGA”)
- Kentucky Oil & Gas Association (“KOGA”)
- Michigan Oil and Gas Association (“MOGA”)
- National Stripper Well Association (“NSWA”)
- North Dakota Petroleum Council (“NDPC”)
- Ohio Oil and Gas Association (“OOGA”)
- Oklahoma Independent Petroleum Association (“OIPA”)
- Pennsylvania Independent Oil & Gas Association (“PIOGA”)
- Texas Alliance of Energy Producers (“Texas Alliance”)
- Texas Independent Producers & Royalty Owners Association (“TIPRO”)
- West Virginia Oil and Natural Gas Association (“WVONGA”)